UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. ___________________

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

AERIAL IMAGES AND VIDEO LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 

OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 

91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 AND DJI INSPIRE 

1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted on January 3, 2016

AERIAL IMAGES AND VIDEO LLC

c/o DAVID R. HEATH, MANAGER

7 CASEY CIRCLE

NASHUA, NEW HAMPSHIRE 03063

603.493.3385
Page 2 of 26

TABLE OF CONTENTS 

Page 

GLOSSARY OF ABBREVIATIONS ....................................................................... 3

SUMMARY................................................................................................................ 4

INTRODUCTION AND INTERESTS OF PETITIONER............................................ 4

BACKGROUND ........................................................................................................ 5

BASIS FOR PETITION............................................................................................... 5

A. NAME AND ADDRESS OF PETITIONER ............................ 7

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

AERIAL IMAGES AND VIDEO LLC SEEKS EXEMPTION .............. 8

C. THE EXTENT OF RELIEF AERIAL IMAGES AND VIDEO LLC

SEEKS AND THE REASON AERIAL IMAGES AND VIDEO LLC 

SEEKS THE RELIEF .......................................................................... 11

D. THE REASONS WHY GRANTING AERIAL IMAGES 

AND VIDEO LLC’S REQUEST WOULD BE IN THE

PUBLIC INTEREST ........................................................................... 13

E. THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY................................ 15

THE REASONS WHY GRANTING AN EXEMPTION

FROM THE REQUIREMENTS OF 61.113(A) AND (B)

WOULD NOT ADVERSELY AFFECT SAFETY........................................... 22

CONCLUSION ......................................................................................................... 23

EXHIBITS
Page 3 of 26

GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of2012 (FMRA) 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System

sUAS Small Unmanned Aircraft System (under 55 pounds Gross Weight)

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

DJI UAV manufacturer 

ESC Electronic speed control 

FPV First Person View 

LI-PO Lithium Polymer battery 

RCV Radio Controlled vehicle 
Page 4 of 26

SUMMARY 

AERIAL IMAGES AND VIDEO LLC seeks exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

AERIAL IMAGES AND VIDEO LLC to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography for marketing, film sets, 

real estate photography, commercials, special events, wedding cinematography, and 

landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is DAVID R. HEATH, and I am the Manager and co-owner of AERIAL IMAGES 

AND VIDEO LLC. I also hold a Commercial pilot certificate with Multi-engine and 

instrument ratings, along with a 3rd Class Medical Certificate. 

DAVID R. HEATH is also a drone builder and operator (pilot) with expertise and knowledge 

in aspects of building, programing and operating multiple types of UAS'S along with camera 

set up and operation. DAVID R. HEATH is also an experienced professional photographer

who provides clients with the highest quality digital content for use in their commercial, 

personal, and non-profit multimedia projects. DAVID R. HEATH is a member of the 

Academy of Model Aeronautics (“AMA”) and has 17 years of Radio Controlled aircraft 

experience including helicopters. 

The objective of AERIAL IMAGES AND VIDEO LLC’s aerial video and photography 

operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, along with testing of repaired drones for clients in a safe testing location 

away from all obstacles and people at all times. AERIAL IMAGES AND VIDEO LLC will 

also provide knowledge of sUAS to others and promote safe sUAS operations. 
Page 5 of 26

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom Vision 2 Plus, DJI Inspire 1

AERIAL IMAGES AND VIDEO LLC seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 2 Vision + and DJI Inspire I are 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Plus has a 

maximum gross weight of approximately 2 pounds 7 ounces, while having a length of 16 

inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 

knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Phantom 2 and DJI Inspire l UA’s are equipped with four 

main rotors; driven by electric motors powered by a Lithium Polymer battery. 

The DJI Phantom 2 and DJI Inspire 1 sUAS’s that will be operated by AERIAL IMAGES 

AND VIDEO LLC will be registered in accordance with 49 U.S.C. 44103, Registration of

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 

14 C.F.R. Part 45, Identification and Registration Markings. 

BASIS FOR PETITION 

Petitioner, AERIAL IMAGES AND VIDEO LLC, pursuant to the provisions of the Federal 

Aviation Regulations (14C.F.R. § 11.61) and the FAA Modernization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 2 and the DJI Inspire 1

sUAS in the National Airspace System (NAS), and for an exemption from the requirements 

of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.119, 91.121, 91.l51(b), 91.405(a), 91.407(a)(I), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, AERIAL IMAGES AND VIDEO LLC operation of DJI 

Phantom 2 and DJI Inspire 1 sUAS’s meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. 

Accordingly, AERIAL IMAGES AND VIDEO LLC requests relief from Sections 91.405(a), 

91.407(a)(I), 91.409(a)(I) & (a)(2), and 91.417 (a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

AERIAL IMAGES AND VIDEO LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. AERIAL IMAGES AND VIDEO LLC will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the sUAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 

Instruction Manual). Furthermore, AERIAL IMAGES AND VIDEO LLC will document and 

maintain all maintenance records for the DJI Phantom 2 and DJI Inspire 1 sUAS. 
Page 6 of 26

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by AERIAL IMAGES AND VIDEO LLC to 

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

DJI Phantom 2 and DJI Inspire 1 sUAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

AERIAL IMAGES AND VIDEO LLC seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 2 and DJI Inspire 1 sUAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, AERIAL 

IMAGES AND VIDEO LLC submits that he will ensure that the DJI Phantom 2 and DJI 

Inspire l sUAS are in an airworthy condition, prior to every flight, by determining that the 

sUAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Phantom 2 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition 

for safe flight. 

AERIAL IMAGES AND VIDEO LLC also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 and DJI Inspire 1 UAs will 

not have a typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 2 and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the 

UA to the GCS for active monitoring of the flight path. This altitude information, combined 

with AERIAL IMAGES AND VIDEO LLC operation of the DJI Phantom 2 and DJI Inspire 

1 sUAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, AERIAL IMAGES AND VIDEO LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. 

AERIAL IMAGES AND VIDEO LLC submits that safety will not be affected by operation 

of the DJI Phantom 2 and DJI Inspire 1 sUAS’s during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power 

to fly for a total duration of approximately 15.5 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.
Page 7 of 26

In accordance with 14 C.F.R. § 11.81, DAVID R. HEATH provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

AERIAL IMAGES AND VIDEO LLC

David R. Heath, Manager

7 Casey Circle

Nashua, New Hampshire 03063

603.493.3385

drh916@me.com
Page 8 of 26

B. The Specific Sections Of 14 C.F.R. from Which AERIAL IMAGES AND VIDEO 

LLC Seeks Exemption. 

1. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements 

Of Section 61.1l3(a) and (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

Subsections (a) and (b) prescribe the following, in relevant part: 

a. No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as PIC of an aircraft. 

b. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment ifi. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or property for compensation or hire.

2. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements 

Of Section 91.7(a).

Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) 

No person may operate a civil aircraft unless it is in an airworthy condition.

3. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements 

Of Section 91.121. 

a. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating-Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) 

of this section, the current reported altimeter setting of an appropriate 

available station;

(iii)In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available 

before departure. 

4. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements 

Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: (b) No person may begin a flight in a rotorcraft under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough 

fuel to fly to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 20 minutes. 
Page 9 of 26

5. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirement Of 

Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a) states the following: Each 

owner or operator of an aircraft:

a. Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter

6. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements 

Of Section 91.407(a)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration;

a. Subsection (a)(1), states the following: No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §43.7 of 

this chapter 

7. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements 

Of Sections 91.409(a)(1) And 91.409(a)(2). 

a. Section 91.409, entitled Inspections, subsection (a), states the following: 

i. Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had –

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; 

or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b).

a. Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

i. Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100 hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include

(a) A description (or reference to data acceptable to the Administrator) of 

the work performed; and
Page 10 of 26

(b) The date of completion of the work performed; and

(c) The signature, and certificate number of the person approving the 

aircraft for return to service. 

Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii)The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv)The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi)Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

b. The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for I year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 
Page 11 of 26

C. The Extent Of Relief AERIAL IMAGES AND VIDEO LLC Seeks And The Reason 

AERIAL IMAGES AND VIDEO LLC Seeks The Relief. 

1. Relief From Section 61.113(a) And (b):

a. Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct 

the proposed UAS flight operations for compensation or hire. This relief is requested 

since the limitations set forth in Section 61.113(a) and (b) state that a private pilot 

may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. As set forth more fully below, AERIAL IMAGES AND 

VIDEO LLC submits that an equivalent level of safety will be maintained because 

no PIC will be allowed to operate the DJI Phantom 2 UAS or DJI Inspire 1 UAS 

unless that PIC has met certain flight-hour and currency requirements, demonstrating 

that the PIC is able to safely operate either the DJI Phantom 2 or DJI Inspire 1 UAS 

in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures. Further, AERIAL 

IMAGES AND VIDEO LLC submits that all flights of the DJI Phantom 2 and DJI

Inspire 1 sUAS, conducted by the PIC pursuant to the grant of this Petition: (1) will 

be incidental to AERIAL IMAGES AND VIDEO LLC’s business; and (2) will not 

carry passengers or property for compensation or hire.
Page 12 of 26

b. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow AERIAL IMAGES AND VIDEO LLC to determine that 

the DJI Phantom 2 and DJI Inspire 1 sUAS are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., 

AERIAL IMAGES AND VIDEO LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). 

AERIAL IMAGES AND VIDEO LLC seeks the requested relief because the DJI 

Phantom 2 and DJI Inspire 1 sUAS do not require an airworthiness certificate in 

accordance with 14 C.F .R. Part 21, Subpart H. Therefore, AERIAL IMAGES AND 

VIDEO LLC will ensure that the DJI Phantom 2 and DJI Inspire 1 sUAS are in 

airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 User Manuals; prior 

to every flight, and further, determine that the aircraft are in condition for safe flight, 

as stated in the conditions and limitations below.Relief from Section 91.121, entitled 

Altimeter settings, may be required to allow flight operations of the DJI Phantom 2

and DJI Inspire 1 sUAS, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC at the ground control station (GCS). Since the FAA requires 

that any altitude information concerning UAS operations be reported to air traffic 

control (ATC) in feet above ground level (AGL), AERIAL IMAGES AND VIDEO 

LLC seeks the requested relief because the DJI Phantom 2 and DJI Inspire 1 UA's 

altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. Considering the limited altitude of the 

proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to 

comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2

and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the 

UA on the heads-up display of the GCS. 

c. Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 

DJI Phantom 2 and DJI Inspire 1 sUAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration 

of approximately15.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. AERIAL IMAGES 

AND VIDEO LLC seeks the requested relief because without an exemption from 

Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 2 and 

DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still 

photo flight operations that AERIAL IMAGES AND VIDEO LLC proposes to 

conduct pursuant to this Petition. Significantly, as set forth below, the technical 

specifications of the DJI Phantom 2 and DJI Inspire 1 sUAS, the DJI Phantom 2 and 

DJI Inspire 1 operating documents, and the operating limitations proposed by 

AERIAL IMAGES AND VIDEO LLC, ensure that AERIAL IMAGES AND 

VIDEO LLC will safely operate the battery powered DJI Phantom 2 and DJI Inspire 

1 sUAS during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 
Page 13 of 26

minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. 

d. Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, AERIAL IMAGES AND VIDEO 

LLC requests relief from these Sections because the DJI Phantom 2 and DJI Inspire 1 

sUAS do not require airworthiness certificates. As set forth more fully below, the DJI

Phantom 2 and DJI Inspire 1 sUAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, AERIAL IMAGES 

AND VIDEO LLC will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the sUAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., AERIAL IMAGES AND VIDEO 

LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and 

DJI Inspire 1 Instruction Manual). Furthermore, AERIAL IMAGES AND VIDEO 

LLC will document and maintain all maintenance records for the DJI Phantom 2 and 

DJI Inspire 1 sUAS. 

D. The Reasons Why Granting AERIAL IMAGES AND VIDEO LLC Request

Would Be In The Public Interest: That Is, How It Would Benefit The Public As A 

Whole. 

Granting the present Petition will further the public interest by allowing 

AERIAL IMAGES AND VIDEO LLC to safely, efficiently, and economically 

perform aerial video and photography of construction sites, real estate, and landscape 

over certain areas of the United States. 

Additionally, use of the DJI Phantom 2 and DJI Inspire 1 sUAS will decrease 

congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and 

provide significant benefits to the economy. Notably, the benefits of AERIAL IMAGES 

AND VIDEO LLC’s proposed operation of the DJI Phantom 2 and DJI Inspire 1 sUAS will 

be realized without conflicting with or violation of any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 2 and DJI Inspire 1 UAs are battery powered and serve as a safe, 

efficient, and economical alternative to the manned aircraft traditionally utilized to 

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform 

aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 or DJI Inspire 

1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the 

ground. Furthermore, by reducing the number of manned aircraft operating in the 

NAS, congestion around airports caused by arriving and departing aircraft will be 

reduced. The DJI Phantom 2 and DJI Inspire 1 UAs do not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2

and DJI Inspire 1 sUAS. 
Page 14 of 26

Conducting aerial media acquisitions with the DJI Phantom 2 and DJI Inspire 1 

sUAS, instead of manned aircraft, will greatly benefit the public by drastically 

reducing the levels of air and noise pollution generated during traditional aerial video 

and still photography flight operations. By using battery power and electric motors, 

the DJI Phantom 2 and DJI Inspire 1 sUAS produce no air pollution, and is the most 

viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography

which burn approximately 20-30 gallons per hour of leaded aviation fuel. The DJI 

Phantom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial 

acquisitions, also eliminate noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine. By using the DJI 

Phantom 2 and DJI Inspire 1 sUAS to perform aerial acquisitions, the substantial risk 

to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or 

completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Phantom 2 and DJI Inspire 1 UAs (weighing approximately 2 

pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross 

weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches 

and 17.7 inches respectively, and with no fuel on board), has less physical potential 

for collateral damage to life and property on the ground, and in the air, compared to 

the manned aircraft that typically conduct similar operations (weighing approximately 

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a 

fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2

and DJI Inspire 1 sUAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 and DJI Inspire 1 sUAS are 

also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 2 and DJI Inspire 1 sUAS will 

allow United States based companies, such as AERIAL IMAGES AND VIDEO 

LLC to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Phantom 2 and DJI Inspire 1 sUAS

utilizes technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 and 

DJI Inspire 1 sUAS, companies such as AERIAL IMAGES AND VIDEO LLC can 

remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial 

use of the DJI Phantom 2 and DJI Inspire 1 sUAS, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad.

4. There Are No Privacy Issues.
Page 15 of 26

Similar to the manned aerial media acquisition flight operations that have been 

conducted for decades, AERIAL IMAGES AND VIDEO LLC proposed operation 

of the DJI Phantom 2 and DJI Inspire 1 sUAS would not implicate any privacy issues. 

Specifically, the DJI Phantom 2 and DJI Inspire 1 sUAS will be operated only in 

compliance with operating documents (i.e., AERIAL IMAGES AND VIDEO LLC

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI 

Inspire 1 Instruction Manual) which requires property owner involvement as well as 

local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 
Page 16 of 26

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which AERIAL IMAGES AND VIDEO LLC Seeks 

Exemption. 

1. Reasons Why The DJI Phantom 2 and DJI Inspire 1 sUAV Meet The Conditions Of 

The FAA Modernization and Reform Act of 2012 (FMRA) Section 333:

2. In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, AERIAL IMAGES AND VIDEO LLC’s 

operation of the DJI Phantom 2 and DJI Inspire 1 sUAS meet the conditions of

FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to 

operate without airworthiness certification and sets forth requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

a. In General. --Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required 

by section 334 of this Act. 

b. Assessment of Unmanned Aircraft Systems. --In making the determination 

under subsection (a), the Secretary shall determine, at a minimumi. Which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and whether a certificate of waiver, 

certificate of authorization, or airworthiness certification under section 

44704 of title 49, United States Code, is required for the operation of 

unmanned aircraft systems identified under paragraph (J). 

c. Requirements for Safe Operation. --If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system. 
Page 17 of 26

In seeking this exemption, AERIAL IMAGES AND VIDEO LLC submits that the DJI 

Phantom 2 and DJI Inspire 1 sUAS can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 and DJI Inspire 1 

sUAS, (b) the pilot certification requirement and (c) the specific operating limitations. 

i. The Specifications Of The DJI Phantom 2 and DJI Inspire 1 sUAS

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 and DJI Inspire 1 sUAS do not create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security considering its 

size, weight, speed, and operational capability. 

ii. Technical Specifications Of The DJI Phantom 2 and DJI Inspire 1 sUAS.

The DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attached 

hereto as Exhibits A and B, set the technical specifications of the DJI Phantom 2

and DJI Inspire 1 sUAS forth. 

iii. The DJI Phantom 2 and DJI Inspire 1 sUAS Autonomous Flight And 

Navigation Modes Enable The sUAS To Remain Within A Defined

Operational Area. 

The DJI Phantom 2 and DJI Inspire 1 sUAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 2 and DJI Inspire 1 sUAS is provided at 

pages 25-35 of the DJI Phantom 2 and pages 12-16 and 45-50 of the DJI Inspire I 

User Manuals, attached hereto as Exhibit C and D. 

iv. The DJI Phantom 2 and DJI Inspire 1 sUAS Are Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The Control Link 

Or Navigation.

When the Control Link is lost, the DJI Phantom 2 and DJI Inspire 1 UAs will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 2 and DJI Inspire 1 UAs do not reacquire control link data from the 

GCS, the UAs will assume that the Control Link is lost and the UAs will return to 

the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. A complete description of the Failsafe Functions of the 

DJI Phantom 2 UAS are set forth at pages 27 and 28 and for the DJI Inspire 1 at 

pages 13 through 15 of the DJI Phantom 2 along with complete DJI Inspire 1 User 

Manuals, attached hereto as Exhibit C and D.

v. The DJI Phantom 2 and DJI Inspire 1 Ground Control Station (“GCS”) And 

It's Operation. 

A complete description of the operation and specifications of the DJI Phantom 2

and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 

44 of the DJI Phantom 2 User Manual and pages 23 through 33 of the DJI Inspire 

1 User Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached 

hereto as Exhibits C and D. 
Page 18 of 26

vi. Flight Operations Of DJI Phantom 2 and DJl Inspire 1 sUAS Are Limited To 

The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer.

vii. AERIAL IMAGES AND VIDEO LLC will only utilize certificated pilots who 

possess a current and valid airman medical certificate to act as a pilot in command 

(PIC) of the DJI Phantom 2 and DJI Inspire 1 sUAS. Additionally, a safety 

observer will assist all pilots during flight time. 

viii. Flights Of DJI Phantom 2 and DJI Inspire 1 sUAS Will Be Conducted

Pursuant To Specific Operating Limitations. 

In seeking this exemption, AERIAL IMAGES AND VIDEO LLC proposes to 

commercially operate DJI Phantom 2 and DJI Inspire 1 UAs for the special purpose 

of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft sUAS

weighing less than 55 pounds maximum gross weight: DJI Phantom 2 and 

OJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting 

operations for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 500 feet above 

ground level (AGL), as indicated by the procedures specified in the 

operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC 

at all times. This requires the PIC to be able to use human vision unaided 

by any device other than corrective lenses, as specified on the PIC's 

FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is 

not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all 

times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must 

ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 
Page 19 of 26

9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant 

of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It 

is the operator's responsibility to track such revisions and present updated 

and revised documents to the Administrator upon request. The operator 

must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which 

the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA's UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition f or safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating 

until the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. The Ground Control Station must be 

included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the 

UAS operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts 

the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit 

requirements. 

14. The operator must carry out its maintenance, inspections, and record 

keeping requirements, in accordance with the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

15. Each sUAS operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between 

inspections. 
Page 20 of 26

17. The PIC must possess at least a private pilot certificate and at least a 

current third-class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51 (b). Flights for the purposes of 

training the operator's PICs are permitted under the terms of the 

exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. 

§91.119.

19. UAS operations may not be conducted during night, as defined in 14

C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of 

operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference 

point as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport's management is obtained, and the 

operation is conducted in accordance with a NOTAM as required by the 

operator's COA. The letter of agreement with the airport management 

must be made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a 

pre-determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 25% 

battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airman (NOTAM) not more than 72 hours 
Page 21 of 26

in advance, but not less than 48 hours prior to the operation. All operations 

shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified 

by serial number, registered in accordance with 14 C.F.R. part 47, and 

have identification (N-Number) markings in accordance with 14 C.F .R. 

part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time 

the UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or 

vehicle. 

31. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, operator 

trainees or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons 

remain under such protection. Ifa situation arises where 

nonparticipating persons leave such protection and are within 500 feet 

of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not 

present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable 

COA must be reported to the FAA's UAS Integration Office (AFS-80) 
Page 22 of 26

within 24 hours. Accidents must be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB Website: 

www.ntsb.gov.
Page 23 of 26

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And 

(b) Would Not Adversely Affect Safety.

AERIAL IMAGES AND VIDEO LLC submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained because no PIC will be 

allowed to operate the DJI Phantom 2 and DJI Inspire 1 sUAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering AERIAL IMAGES AND VIDEO LLC’s proposed area of operations, 

and the operating limitations set forth-above; the parallel nature of private pilot 

aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI 

Phantom 2 or DJI Inspire 1 UAS, AERIAL IMAGES AND VIDEO LLC submits 

that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for AERIAL IMAGES AND 

VIDEO LLC’s specific proposed flight operations. The FAA has previously granted 

relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161). AERIAL IMAGES AND VIDEO 

LLC will not allow any PIC to operate the DJI Phantom 2 or DJI Inspire 1 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or 

the DJI Phantom 2 or DJI Inspire 1 UAS training and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 

14 C.F.R. § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption). In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). As in Exemption Nos. 11062,11138, and 11153, prior 

documented flight experience that was obtained in compliance with applicable 

regulations will ensure an equivalent level of safety during AERIAL IMAGES AND 

VIDEO LLC’s proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: In Exemption No. 

11062, the FAA required that prior to conducting operations for the purpose of

motion picture filming (or similar operations), the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also 

have accumulated and logged a minimum of 5 hours as a sUAS pilot operating the 

same make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive 

rather than additive; i.e. 5 hours make and model time may be included in the 10 

Page 25 of 26

EXHIBIT A 

DJI PHANTOM 2 VISION + 

TECHNICAL SPECIFICATIONS

AERIAL IMAGES AND VIDEO LLC only utilizes safe and reliable sUAS. DJI is an 

industry leader in small UAS production. DJI sUAS are complete with leading edge and proven

software enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also he set to limit flight to no higher than a predetermined and set altitude as 

well as limit flight to a predetermined and set distance. In addition, DJI software provides 

real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices) 

DJI Phantom 2

1.1 Aircraft 

1.1.1 Supported Battery -DJI 5,200mAh 2S LiPo Battery 

1.1.2 Weight (Battery & Propellers Included) -2 lbs 11.81 oz (1,242g) 

1.1.3 Hover Accuracy (Ready to Fly) -Vertical: .8m; Horizontal: 2.5m 

1.1.4 Max Yaw Angular Velocity 200°/s 

1.1.5 Max Tilt Angel 35°

1.1.6 Max Ascent / Descent Speed: Ascent 6m/s Descent 2m/s 

1.1.7 Max Flight Speed-15m/s (NOT RECOMMENDED) 

1.2 Gimbal 

1.2.1 Working Current -Static: 750mA; Dynamic: 900mA 

1.2.2 Control Accuracy -±O.03°

1.2.3 Controllable Range -Pitch: 90° to 0°

1.2.4 Maximum Angular Speed Pitch: 90°/s 

1.3 Camera 

1.3. 1 Operating Temperature Range 32°F - 104°F (O°C to 40°C) 

1.3.2 Sensor Size 1⁄2.3" 

1.3.3 Effective Pixels: 14 Megapixels

1.3.4 Resolution 4384x3288px

1.3.5 HD Video Recording: 1080p 30 & nop 

1.3.6 Recording Field of View: 110°/85°
Page 26 of 26

EXHIBIT B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

AERIAL IMAGES AND VIDEO LLC only utilizes safe and reliable sUAS. DJI is an 

industry leader in small UAS production. DJI sUAS are complete with leading edge and proven 

software enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set altitude as 

well as limit flight to a predetermined and set distance. In addition, DJI software provides 

real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices) 

DJI Inspire 1

1.1 Aircraft 

1.1.1 Model -T600 

1.1.2 Weight (Battery Included) -6 lbs 7.52910z (2,935g) 

1.1.3 Hovering Accuracy (GPS Mode) -Vertical: 0.5m; Horizontal: 2.5m 

1.1.4 Max Angular Velocity: Pitch: 300°/s; Yaw: 150°/s

1.1.5 Max Tilt Angle: 35°

1.1.6 Max Ascent Speed: 5m/s 

1.1.7 Max Descent Speed: 4m/s 

1.1.8 Max Speed: 22m/s (ATTI mode, no wind-NOT RECOMMENDED) 

1.1.9 Max Flight Altitude 4,500m MSL

1.1.10 Max Wind Resistance: 10m/s 

1.1.11 Max Flight Time -Approximately 18 minutes 

1.1.12 Motor Model: DJI 3510 

1.1.13 Propeller Model: DJI 1345 

1.1.14 Operating Temperature Range: 14°F to 104°F (-10°C to 40°C) 

1.1.15 Dimensions 438x451x201 mm 17.25” x 17.76" x 7.9" 

1.2 Gimbal 

1.2.1 Model: ZENMUSE X3 

1.2.2 Output Power (with camera): Static: 9W; In Motion: 11 W 

1.2.3 Operating Current -Static: 750mA; In Motion: 900mA 

1.2.4 Angular Vibration Range -±0.03 ° 

1.2.5 Mounting -Detachable 

1.2.6 Controllable Range: Pitch: -90°to +30°; Pan: ±320°

1.2.7 Mechanical Range: Pitch: -125° to +45°; Pan: ±330°

1.2.8 Max Controllable Speed: Pitch: 120°/s; Pan: 180°/s

1.3 Transmitter 

1.3.1 Name-CI 

1.3.2 Operating Frequency 5.728 to 5.850 GHz; 2.400-2.483GHz 

1.3.3 Communicating Distance (unobstructed): 3.1 miles

1.3.4 Output Power -9W 

1.3.5 Operating Temperature Range -14°F to 104°F (-10°C to 40°C)

1.3.6 Battery 4,500mAh 2S or optional 5,700mAh LiPo 2S 

All specifications can be found in the attached user manual or at 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf